Deeming section 50C cannot override section 45(3)

ACIT Vs Amartara Pvt. Ltd. (ITAT Mumbai) Deeming section 50C cannot override another deeming section 45(3) which is specifically created by Income Tax Act, 1961 The issue under consideration is whether A.O. is correct by adding long term capital gains by applying section 50C in case where land is transferred by the partner in his firm as capital contribution? The Hon’ble Tribunal has held that the deeming section provided in Section 50C cannot be extended to another deeming section created by the statue by Section 45(3). The Tribunal has noted that since the Act itself has provided for d...